In one of the most emotionally affecting scenes since Gotham began, Carmine Falcone found out that his girlfriend, Liza, was actually planted by Fish Mooney, in order to convince him to leave the mob and get out of the game. And his reaction was to strangle her, making her an almost totally innocent victim of the ongoing mob war. But is Liza actually dead? In comic books, you can never tell if a character is really dead, or if they'll end up returning in a few issues, now with an ax to grind with the person who "killed" them.
Falcone could have simply pretended to kill her because he's really fallen in love with her, but something tells me that would backfire terribly for him (kill me once, shame on you, bring me back to life once, I won't give you the chance to kill me again), and I don't know how he would have signaled to her that she should play dead. So if Liza did live, it's either because Falcone is pretty bad at strangling people, or because she has the power to come back from the dead.
But sorry, Liza fans, I don't think that we'll be seeing her again. It really seems like the show put a final bookend on her character, and nothing in the upcoming trailers or episode descriptions point at her being revived. There are a multitude of reasons, both artistic and logistic, that point at Liza's story being finished.
Her Thematic Purpose Is Completed
I guess anything can happen, but I think that was the last time that we'll see Liza alive. She represented Falcone's weakness, his vulnerability to Fish, and now that he knows exactly how much she betrayed him, the wool is no longer over his eyes. He won't make the mistake of believing anything she has to say ever again.
There Are Only A Few Batman Characters Who Can Come Back From The Dead
The most famous undead Batman villain is R'as al Ghul, who uses a Lazarus Pit, a portal that allows his body to regenerate and come back to life after death. Not only does that not fit the realistic tone of Gotham so far, but it's also probably a no-go because R'as is currently acting as a major villain over on The CW's Arrow . While DC owns the character, I don't think FOX wants a second class copy of another network's character.
Makenzie Leigh Is In High Demand
The actress who plays Liza, Makenzie Leigh, has taken recurring roles on two other shows this season, so I don't think she's going to be a big part of the last few Gotham episodes. She was a small part of Mozart in the Jungle Season 1, playing Addison, the ballerina who was a romantic threat over dancer Alex. And NBC has snatched Leigh away to The Slap, where she plays a babysitter wrapped up in the scandal around a parent slapping someone else's child. At least if we won't be seeing her on Gotham again, there are still other places to catch Leigh.